Pro Se Representation of Estate

Order by trial court directing the administrator of an estate to retain counsel to maintain appeal from tax sale affirmed because (a) the order was a collateral order appealable under Pa. R.A.P. 313, and (b) an administrator may not represent the estate pro se unless the administrator is the sole beneficiary and there are no creditors, because this would be the unauthorized practice of law.  Estate of Anna S. Rowley, 84 A.3d 337, 4 Fid. Rep. 3d 249, No. 444 C.D. 2013 (Cmwlth. 2013) (Opinion by Pellegrini, President Judge), app. den., 149 WAL 2014 (Pa. 8/19/2014).

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